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to discrepancies found in the Peabody topsoil depth estimates. A mitigation plan was approved <br />by the Division and implemented by the mine in 1996. <br />Whenever possible, topsoil was live hauled to active reclamation areas. However, this was not <br />always possible (particularly in the case of acreage designated as Prime Farmland), and some <br />topsoil was stockpiled. Stockpiled topsoil will be protected from wind and water erosion by <br />roughening and ditching around the pile, establishing an annual cover crop, or establishing a <br />perennial grass cover, depending on the length of time a stockpile will be in place. <br />Overburden was removed by shovel and trucks after an area was drilled and shot. An ANFO slurry <br />was the primary agent used in the blast. All shots were monitored with seismographs located at <br />structures nearest to the blast. All blasting was completed by June 2013. <br />Mining began along the eastern subcrop of the NHM area and continued west through the BB <br />Road and the 2700 Road to the final cut which was located between Ponds 15 and 13. A panel <br />mining method was used to develop the pits (see Map 2.05.2-1). The panels varied in length, up <br />to 3,500 feet. The panel width was typically 100 to 120 feet. The overburden was excavated using <br />a shovel and trucks and then placed or pushed into an adjacent or nearby mined -out pit. <br />The reclamation plan is designed to replace agricultural lands using irrigation water from the CCC <br />Ditch. The remaining areas will be planted to dryland pasture. It is anticipated that wetland <br />vegetation will establish in low spots and adjacent to impoundments on the reclaimed landscape, <br />due to the presence of water from irrigation runoff. Continued incidental use of the reclaimed <br />landscape by wildlife similar to that which occurred prior to mining is expected. <br />Operations on Prime Farmland <br />There are two areas of designated Prime Farmland within the permit area. The first is the Morgan <br />property, southwest of the 2700 Road and BB Road intersection, which is dominated by Darvey- <br />Barx complex soils (map unit 98E). The second is in the northwest corner of the permit area and <br />is dominated by Begay soils (map unit 98A) on land owned by ERMR. Approximately 3.96 acres <br />has been disturbed by mining operations. ERMR will manage and reclaim these areas in <br />accordance with Prime Farmland requirements of Rule 2.06.6 and 4.25, as discussed in Section <br />XVIII of this document. <br />Water Rights and Usage <br />The water rights, usage and augmentation plan is presented in Section 2.05.6(3) of the permit <br />application. There are 11 surface water rights and 29 water wells adjacent to the mine sites. <br />The monitoring plan is described in Section B, Item II E, of this Findings Document. The plan is <br />detailed enough to show any impacts on adjacent water rights to the NHM. ERMR has shown that <br />it has adequate water rights to mitigate any discovered impacts and this complies with the <br />requirements of 4.05.15. <br />17 <br />